Page 3 - PowerPoint Presentation

ASSISTANCE CORNER SPOTLIGHT : KOP 2.1a Section 30.4.2 – KYC Requirements for ASL & AAR

Insights Log When dealing with cases of ASL (Agency Securities Lending) and AAR (As Agent Repo), the business should ensure it has valid

This excel document provides all instances of query clarifications provided by KYC profile for the client and appropriate due diligence is performed on the counterparty in the lending transaction.
DB through any formal channels and notification of changes. Services Client KYC Requirements
Analysts can do a Keyword search through Search functionality and all relevant Both Client (Lender) and Counterparty  KYC on the Client and Counterparty in line with client type and risk rating.
results will be displayed. (Borrower) are clients of DB  Perform NLS on any relevant non-clients parties involved in the transaction

Comms Library ASL or AAR  Where Agent is DB-recognised regulated entity, Perform KYC (SDD) on the Agent
Where Client or Counterparty and NLS on the UP
This excel document provides all notification of changes along with the transactions (e.g. IM) is an Agent acting on behalf  Where Agent is not DB-recognised regulated entity or where DB is engaging
confirmation mail, process / policy referral documents
of an Underlying Principal (e.g. Fund) directly with UP, Perform KYC on both the Agent and UP
Click here to access both documents  Perform NLS on any relevant non-clients parties involved in the transaction
The two documents above are also located in the shared drive within DB For KYC requirements on:
environment.  Custody and Clearing services, refer section 30.4.1

(“KYC Process Documentation” folder in Y:\KYC_PR_ACN_GLOBAL_3)  Domestic and Alternative Fund Services, refer section 30.4.4

Outreach Reminders… LEARNINGS FROM QUALITY ANALYSIS… FinCEN

 Financial Crime Enforcement
 COB teams should have access to DB AMINET, which can be 1. Screening continues to be a primary fail theme – as identified during SWAT reviews, Network (aka FinCEN) is a bureau
referred to as a secondary source for DB-owned entities screening of previous/alias names, incorrect LR names continues to be a challenge of the U.S. Department of the
QUALITY 2. Errors in identifying all Legal Representatives were evident once again, which has Treasury and also serves as the FIU
 We must not send cases to outreach if they are marked ‘EDR’ increased the screening errors (Financial Intelligence Unit) for the
and there are no docs in the EDR folder. This must be raised United States and is one of more
with Pipeline 3. NACE Code identification based on Nature of Business is an additional learning. We must than 100 FIUs making up the
raise an RDS request when we are unable to determine appropriate NACE code for the
entity Egmont Group, an international
 Policy has confirmed on call that SCR from controllers are entity focused on information sharing
acceptable (corporate or project controller). For confirmation 4. Incorrect entity template selection has been on the rise. This directly impacts CRRE and cooperation among FIUs
received by project controllers, we need to verify if it is the entity calculation resulting in a lower/higher risk rating. We must ensure that the correct entity  Its mission is to safeguard the
project template is chosen every time financial system from illicit use,
5. We must make sure that dbCAR static information is complete. Errors, like PEP status not combat money laundering and
 SCR from counsel (general or associate) is acceptable selected correctly or missing investment manager details, have been noticed frequently promote national security, under its
motto “Follow the Money”

IN OTHER ANNOUNCEMENTS… BRAIN Angel lies on Mondays, Tuesdays and Wednesdays but tells the truth the rest of  It partners with law enforcement at
and
government
all
levels
of
the week. Brenda lies on Thursdays, Fridays and Saturdays, but tells the truth
To mark the successful completion of Phase 2, our TEASER every other day. supports the nation's foreign policy
Newcastle & Mumbai counterparts threw a celebratory Angel : Yesterday, I was lying. and national security objectives
party! Check out the pictures for all the fun! Brenda : So was I! Read more about FinCEN here –
What day was it? https://www.fincen.gov/what-we-do

Let us know your feedback or if you want to be featured at 14 th MAY 2018
prem.parth@accenture.com